Dr James Knapton
Information Compliance Officer
Shane Davies
By email
Reference: FOI-2018-340
7 June 2018
Dear Mr Davies,
Your request was received on 15 May 2018 (across two emails) and I am dealing with it under the
terms of the Freedom of Information Act 2000 (‘the Act’).
You asked:
I would be very grateful if you could provide a comprehensive list of the University's current
endowment investment assets, including the names of the investment managers and funds.
[…]
Additionally, please detail any professional investment advisory or consultancy services or firms
used for endowment fund investments.
The majority of the University’s investments are invested in units of the Cambridge University
Endowment Fund (CUEF), a collective investment scheme in the form of a unit trust in which the
University, its Colleges and other charities linked with the University are permitted to invest. This unit
trust is managed and operated by Cambridge Investment Management Limited (CIML), a wholly-owned
subsidiary of the University. Information relating to the University’s investments in the CUEF is exempt
under sections 41(1), 43(1) and 43(2) of the Act on the grounds that its disclosure would constitute an
actionable breach of confidence and/or it constitutes a trade secret and/or its disclosure would be likely
to prejudice the commercial interests of the University and/or its fund managers and/or the
funds/companies in which it invests.
In particular, disclosure of the information in question would be likely to weaken the position of the
University and its fund managers in a competitive environment and/or to reveal commercially sensitive
information of potential usefulness to other investors. For example, disclosure would place in the public
domain information which would allow competitors to track and replicate the investment strategies of
the University and/or its investment managers. Additionally, such disclosure would involve the
divulgence of commercially sensitive information about individual portfolio companies and would
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prejudice the University’s ability to attract, engage and retain investment managers of the requisite
expertise and integrity in the future.
Section 41(1) confers absolute exemption under the Act. As sections 43(1) and 43(2) are qualified
exemptions, the University has considered whether, in all the circumstances of the case, the public
interest in maintaining the exemptions outweighs the public interest in disclosing the information. The
University has concluded that there is no overriding interest in disclosure, given in particular the high
degree of commercial prejudice to which disclosure would expose the University and/or its fund
managers and/or the companies/funds in which it invests.
If you are unhappy with the service you have received in relation to your request and wish to make a
complaint or request an internal review of this decision, you should contact us quoting the reference
number above. The University would normally expect to receive your request for an internal review
within 40 working days of the date of this letter and reserves the right not to review a decision where
there has been undue delay in raising a complaint. If you are not content with the outcome of your
review, you may apply directly to the Information Commissioner for a decision. Generally, the
Information Commissioner cannot make a decision unless you have exhausted the complaints
procedure provided by the University. The Information Commissioner may be contacted at: The
Information Commissioner’s Office, Wycliffe House, Water Lane, Wilmslow, Cheshire, SK9 5AF
(https://ico.org.uk/).
Yours sincerely,
James Knapton